SEC Company Response from FS KKR Capital Corp (FSK) (CIK 0001422183) (FSK) — Jul 19, 2016
FS KKR Capital Corp (FSK) (CIK 0001422183)
Date: July 19, 2016 · CIK: 0001422183 · Accession: 0001193125-16-651114
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 814-00757
Letter
VIA EDGAR Securities and Exchange Commission Division of Investment Management, Disclosure Review Office 100 F Street, N.E. Washington, DC 20549 Re: FS Investment Corporation Form 10-K (File No. 814-00757)
Dear Mr. Sandoval:
On behalf of FS Investment Corporation (the “Company”), set forth below is the Company’s response to the oral comment provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in a telephone conversation on July 1, 2016 regarding the Company’s Annual Report on Form 10-K for the year ended December 31, 2015, as filed with the Commission on February 29, 2016. For your convenience, a summary of the Staff’s comment is presented in bold, italicized text below, and such comment is followed by the Company’s response.
Notes to Consolidated Financial Statements
In future filings, please provide additional disclosure in the notes to the financial statements describing the compensation paid to the Company’s investment sub-adviser, even if the compensation is indirect.
In future filings, the Company will include additional disclosure substantially similar to the following disclosure in the Related Party Transactions Note to the Consolidated Financial Statements:
“The investment sub-advisory agreement provides that GDFM will receive 50% of all fees payable to FB Advisor under the July 2014 investment advisory agreement with respect to each year.”
* * * * * * *
Jacob Sandoval
July 19, 2016
Page 2
The Company hereby acknowledges that: (i) the review of these filings by the Commission or the Staff, acting pursuant to delegated authority, does not foreclose the Commission from taking action with the respect to the filing; (ii) the review of these filings by the Commission or the Staff, acting pursuant to delegated authority, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (iii) the Company may not assert the review of this filing by the Commission or the Staff, acting pursuant to delegated authority, as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
* * * * * * *
If you have any questions or if you require additional information, please do not hesitate to contact me at 215-994-2510.
Sincerely,
/s/ James A. Lebovitz
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CORRESP
1
filename1.htm
CORRESP
Cira Centre
2929 Arch Street
Philadelphia, PA 19104-2808
+1 215 994 4000 Main
+1 215 994 2222 Fax
www.dechert.com
JAMES A. LEBOVITZ
james.lebovitz@dechert.com
+1 215 994 2510 Direct
+1 215 655 2510 Fax
July 19, 2016
VIA
EDGAR
Jacob Sandoval
Securities and Exchange
Commission
Division of Investment Management, Disclosure Review Office
100 F Street, N.E.
Washington, DC 20549
Re:
FS Investment Corporation
Form 10-K (File
No. 814-00757)
Dear Mr. Sandoval:
On behalf of
FS Investment Corporation (the “Company”), set forth below is the Company’s response to the oral comment provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and
Exchange Commission (the “Commission”) in a telephone conversation on July 1, 2016 regarding the Company’s Annual Report on Form 10-K for the year ended December 31, 2015, as filed with the Commission on
February 29, 2016. For your convenience, a summary of the Staff’s comment is presented in bold, italicized text below, and such comment is followed by the Company’s response.
Notes to Consolidated Financial Statements
In future filings, please provide additional disclosure in the notes to the financial statements describing the compensation paid to the Company’s
investment sub-adviser, even if the compensation is indirect.
In future filings, the Company will include additional disclosure substantially
similar to the following disclosure in the Related Party Transactions Note to the Consolidated Financial Statements:
“The investment sub-advisory
agreement provides that GDFM will receive 50% of all fees payable to FB Advisor under the July 2014 investment advisory agreement with respect to each year.”
* * * * * * *
Jacob Sandoval
July 19, 2016
Page 2
The Company hereby acknowledges that: (i) the review of these filings by the Commission or the Staff,
acting pursuant to delegated authority, does not foreclose the Commission from taking action with the respect to the filing; (ii) the review of these filings by the Commission or the Staff, acting pursuant to delegated authority, does not
relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (iii) the Company may not assert the review of this filing by the Commission or the Staff, acting pursuant to delegated
authority, as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
* * * * * * *
If you have any questions or if
you require additional information, please do not hesitate to contact me at 215-994-2510.
Sincerely,
/s/ James A. Lebovitz
James A. Lebovitz
Cc:
Stephanie Hui, Esq.
Marianne Dobelbower, Esq.
Christina DiAngelo Fettig
Securities and Exchange Commission
Stephen S. Sypherd
FS Investment Corporation